Documents to View or Download

(Scroll to the bottom of this page to view/download S. Tijerina vs City of Kingsville lawsuit documents)

VZSTx Legislative Packet 2025 is a pdf packet of documents that can be used by Texas Legislators, TxDOT officials, or any Texas Traffic Safety Stakeholder to understand the full agenda of Vision Zero South Texas (to be used in conjunction with the data and photos on this Vision Zero South Texas website). Documents in the packet include the one-page informational flyer, the “Call for Action” letter, Recommendations to TxDOT’s External Partners Workgroup for System Safety, and an Addendum document depicting the recommendation for TxDOT to create a new centralized Safety Division and the recommendation for the Texas Legislature to create a new Texas Traffic Safety Commission that would be very similar to the Commission used in Washington State. Each of these documents listed above are provided separately to be downloaded separately, if desired.

LAYMAN’S BRIEF, AMICUS CURIAE BRIEF, and other documents relating to lawsuit of S. Tijerina vs City of Kingsville (Texas).

Kingsville, Texas (May-Dec 2025, Appeal 2026)

105th District Court, Kleberg County, Texas, issued writ of mandamus sought by plaintiff Selina Tijerina, vs City of Kingsville, Texas, et al. (Court Case Number: 25-377-D).

City of Kingsville appealed to the Court of Appeals, 13th District of Texas (Case Number: 13-25-00622-CV).

Below is the LAYMAN’S BRIEF (revision 13, dated 19March2026) relating to opined violations of the Kingsville City Charter (Texas) during the recall process of three city commissioners in the summer of 2025. It is a layman’s legal opinion with a mission TO PREVENT WASTEFUL SPENDING of Kingsville city tax dollars on unnecessary (adversarial) legal fees and/or an illegal recall election, so that those dollars can be spent on pedestrian safety devices like sidewalks, bike paths, and signage in school zones.

Unfortunately, the mission of the LAYMAN’S BRIEF failed on August 13, 2025, whereas a lawsuit was filed against the City of Kingsville in the 105th District Court, Kleberg County, Texas, by plaintiff Selina Tijerina (Court Case Number: 25-377-D), and appealed by the City of Kingsville in the 13th Court of Appeals (Case Number: 13-25-00622-CV).

A copy of the TIJERINA LAWSUIT against the City of Kingsville (25-377-D) is attached to the DRAFT AMICUS CURIAE BRIEF below, as Exhibit A (page 15).

The AMICUS CURIAE BRIEF, by L. Hamm, is a DRAFT document only, and HAS NOT been filed with the 105th District Court. The AMICUS CURIAE BRIEF is the follow-on document to the LAYMAN’S BRIEF that could be legally submitted to a court for consideration. This document includes exhibits including Plaintiff’s Petition for Writ of Mandamus, Recall Affidavit, Recall Notice to Commissioners, Recall Petition signed by Commissioner Lopez, and City Secretary’s Memo to Commissioners at 23Jun2025 City Commission meeting.

The CITY OF KINGSVILLE’S RESPONSE (by G. Hinojosa, Brownsville, TX, hired Attorney for the City of Kingsville) to the Tijerina Lawsuit is attached below as another document that can be downloaded.

OFFICIAL TRANSCRIPT to case number 25-377-D, 105th District Court, Kleberg County, held on 14 October2025, S. Tijerina vs City of Kingsville, Texas, is attached below. The Judge in this case ruled in favor of S. Tijerina and issued a writ of mandamus ordering the Kingsville City Commission to set a date for a recall election, which the City Commission did and the election date is set for

City of Kingsville’s Appeal to the Court of Appeals, 13th District of Texas. The City’s argument for appeal and expedited schedule is attached below.

Court of Appeals, 13th District of Texas, Order Per Curiam, granting appeal go forward with expedited schedule, is attached below.

Court of Appeals, 13th District of Texas, Appellant Brief dated 30DEC025, is attached below.

Court of Appeals, 13th District of Texas, FINAL JUDGMENT, and its Memorandum Opinion is attached below. The 13th Court of Appeals rendered final judgment on the lawsuit against the City of Kingsville regarding the recall of three City Commissioners. The Court dissolved the Writ of Mandamus ordered by Judge Pulcher in the 105th District Court, effectively canceling the recall election on 02May2026 in the City of Kingsville, Texas.

13th Court of Appeals… “the trial court abused its discretion in issuing the writ because the court failed to correctly apply the Charter. See Walker, 827 S.W.2d at 840. We sustain appellant’s issue.
III. CONCLUSION
The judgment of the trial court issuing the writ of mandamus is reversed and the
writ of mandamus is dissolved.“

Below is also a recommended AGENDA ITEM to the Kingsville City Commission for an “example” agenda item to “right” the “wrong” of the chronologically FIRST violation of the Kingsville City Charter relating to the Kingsville recall process which was the acceptance of the recall petition, and the violation of the thirty (30) day requirement for the recall petition to be returned to the City Secretary, that occurred on 06June2025.